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Privacy Policy

Last updated: March 22, 2026. ZedScript Automações LTDA is committed to the protection of personal data and privacy of FaceDojo users. This policy describes the lifecycle of your data in compliance with the LGPD (Brazil) and the GDPR (European Union). By using our services, you declare awareness and agreement with these guidelines.

1. DATA CONTROLLER

For student data processed inside an academy, the academy or responsible instructor is the data controller, and ZedScript Automações LTDA/FaceDojo acts as processor. For administrative account, contract, billing, support, and internal operation data, ZedScript Automações LTDA may act as controller. Privacy requests are handled by the DPO/Data Protection Officer through the WhatsApp channels listed on the site.

2. PERSONAL DATA COLLECTED

2.1 Data provided by the user

  • Contact data: Name, email, and phone number.
  • Professional profile: Registration information and gym data.
  • Linked data: Information about the unit and team.

2.2 Biometric data (Sensitive)

  • We collect facial biometrics for attendance automation.
  • Usage is restricted to student attendance control.
  • We do not perform data mining of biometric data for advertising.
  • The controlling academy is responsible for defining and maintaining the legal basis and applicable authorizations for facial biometric use.
  • Biometric data remains stored while the academy/responsible instructor remains a FaceDojo customer, unless the student or guardian requests deletion earlier.
  • The student or guardian may request deletion of biometrics at any time through the student portal, the academy, or the DPO/Data Protection Officer.

2.3 Browsing data

  • IP address and access logs.
  • Device type and browser used.
  • Cookies for platform personalization.

3. PURPOSES OF PROCESSING

  • Technical and managerial operation of the platform.
  • Facial recognition for security and attendance.
  • Technical support and customer service.
  • Guaranteeing platform integrity.
  • Compliance with industry regulations.

4. LEGAL BASIS (Compliance)

LGPD Compliance (BR)

  • Service contract execution.
  • Consent for sensitive data.
  • Regular exercise of rights.

GDPR Compliance (EU)

  • Art. 6(1)(b): Execution of a contract.
  • Art. 9(2)(a): Explicit consent for sensitive data.
  • Art. 6(1)(c): Compliance with legal obligations.

5. SHARING

  • Cloud Providers: Scalable storage and processing (AWS/MongoDB).
  • Security and Analytics: Diagnostic tools and continuous improvement.
  • Legal Obligation: Compliance with judicial or administrative orders.

6. INTERNATIONAL TRANSFER

Your data may be processed on global servers. We use Standard Contractual Clauses (SCCs) to ensure that the GDPR/LGPD level of protection is maintained regardless of the physical location of the data.

7. OPERATIONAL SECURITY

  • End-to-end encryption in transit and at rest.
  • Strict policies of least privilege (Least Privilege).
  • Vulnerability scans and 24/7 monitoring.
  • Data redundancy and encrypted backups.

8. RETENTION AND DELETION

  • Operational data is kept while there is an active contractual relationship between the academy/responsible instructor and FaceDojo, observing the purposes of the service.
  • Biometric data remains stored while the academy/responsible instructor remains a FaceDojo customer, unless the student or guardian requests deletion earlier.
  • Deletion of biometric data may be requested at any time by the student or guardian, including through the student portal, the academy, or the DPO/Data Protection Officer.
  • Residual retention of non-biometric data may occur only for tax, legal, contractual obligations, or regular exercise of rights.

9. USER RIGHTS

  • Confirmation and Access to existing personal data.
  • Correction of incomplete or erroneous information.
  • Portability and revocation of consent.
  • Opposition to automated processing (GDPR).

10. CONTACT CHANNEL

To exercise any right provided by law, send your request to the DPO/Data Protection Officer through the WhatsApp channels listed on the site. Students and guardians may also request biometric data deletion through the student portal or directly with the controlling academy.